# Proximus SA: Insufficient involvement of data protection officer

- Type: Enforcement
- Source: Belgian Data Protection Authority (APD)
- Date: 2020-04-28
- Original: https://www.enforcementtracker.com/ETid-272
- Canonical: https://overview.legal/posts/46387
- Topics: Notified Body Responsibilities and Operational Obligations, Supervisory Authorities, Scientific Panel Independence, Law Enforcement, Telecommunications, Data Breaches, Notified Body Independence, Processing Agreement, Processing, Personal Data

## Summary

According to the data protection authority, the company's data protection officer was not sufficiently involved in the processing of personal data breaches and the company did not have a system in place to prevent a conflict of interest of the DPO, who also held numerous other positions within the company (head of compliance and audit department), which led the DPA to the conclusion that the company's DPO was not able to work independently.

## Full text

According to the data protection authority, the company's data protection officer was not sufficiently involved in the processing of personal data breaches and the company did not have a system in place to prevent a conflict of interest of the DPO, who also held numerous other positions within the company (head of compliance and audit department), which led the DPA to the conclusion that the company's DPO was not able to work independently.

GDPR Articles: Art. 31 GDPR, Art. 58 GDPR, Art. 37 GDPR
Industry: Media, Telecoms and Broadcasting

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Generated by overview.legal · https://overview.legal/posts/46387 · 2026-08-22